Last Updated: February 3, 2023
The Wolff Company, LLC, and its subsidiaries and affiliates (collectively, “Wolff,” “us,” “we,” or “our”) respects the privacy of your information. This Privacy Policy (“Privacy Policy”) describes how we may collect, use, and share your personal information in connection with the website, awolff.com, and any other websites and platforms we own and operate that link to this Privacy Policy (collectively, the “Website”), and our related online and offline services, events, social media pages, and email and other electronic communications (collectively, and together with the Website, the “Services”), and the choices you have with respect to your personal information. In some cases, region-specific terms may apply to you, which are indicated in the section headings below.
If you are a current or prospective investor of Wolff and have an online account with us, please view the privacy policies posted within the portal to understand how your personal information may be processed and your rights with respect to your information. Similarly, if you engage with any Wolff property or community, please view the privacy policy available on that property or community website to understand how your personal information may be processed.
Wolff reserves the right, at any time, to modify this Privacy Policy. If we modify how we collect, use, or share personal information, we will post the updated Privacy Policy on this page. In some cases, we may notify you about an update by sending you an email, posting a notice about the update on the Services, or other means as may be required by applicable law. In all cases, your continued use of the Services following posting or other notification of changes constitutes your acknowledgement of such changes. Please review this Privacy Policy periodically to keep up to date on our most current policies and practices.
This Privacy Policy covers the following topics:
COLLECTION OF PERSONAL INFORMATION
SHARING OF PERSONAL INFORMATION
CHOICES ABOUT YOUR PERSONAL INFORMATION
SECURITY OF PERSONAL INFORMATION
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
NOTICE TO CALIFORNIA RESIDENTS
COLLECTION OF PERSONAL INFORMATION
Personal Information You Provide To Us.
If you choose to contact us through the Services, we will collect your first and last name, email address, and the information associated with your requests or inquiries. We may also collect other personal information that is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, or otherwise to us.
Personal Information Automatically Collected
Wolff, our service providers, and our advertising partners may automatically log information about you, your computer, or mobile device, and your activity over time on our Services and other sites and online services. Personal information that may be automatically collected includes:
- Device Information, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, general location information such as city, state or geographic area; and
- Online Activity Information, such as information about your use of and actions on the Services, such as the website you visited before browsing to our Services, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
Like many online services, we use cookies and similar technologies to facilitate some of the automatic data collection described above, such as:
- Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
- Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about the usage of websites and the success of marketing campaigns.
Personal Information Obtained from Third Parties
Wolff may receive personal information from third parties, such as our service providers, advertising partners, data analytics partners, operating systems and platforms, social media platforms, event sponsors, publicly available sources, or data providers. We may merge or combine such personal information with the personal information we collect from you directly or automatically.
Referrals
Users of our Services may have the opportunity to refer contacts and share their contact information. Please do not provide us with someone’s contact information unless you have their permission to do so.
USE OF PERSONAL INFORMATION
Wolff’s primary purpose in collecting personal information is to provide the Services that you request. We also use personal information for the purposes set forth below and as otherwise described in this Privacy Policy or at the time of collection.
To Provide the Services. We may use personal information to provide our Services and operate our business. For example, we use personal information to respond to any of your requests, feedback, or questions, to improve and personalize your experience with the Services, and to verify your identity or determine your eligibility for program and service offers.
Research and Development. We use personal information for research and development purposes, including to study and improve the Services and our business, understand and analyze the usage trends and preferences of our users, and develop new features, functionality, and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from the personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes.
Direct Marketing. We may send you Wolff-related or other direct marketing communications as permitted by law, including materials, updates, information, special offers, and promotional material from us and our business partners. You may opt out of our marketing communications as described in the “CHOICES ABOUT YOUR PERSONAL INFORMATION” section.
Interest-Based Advertising. We work with third-party advertising companies and social media companies to help us advertise our business and to display ads for our communities and services. These companies may use cookies and similar technologies to collect information about you (including the online activity information and device information described above in the section called “Personal Information Automatically Collected”) over time across our Services and other websites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. In addition, some of these companies may use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms. You can learn more about your choices for limiting interest-based advertising in the “CHOICES ABOUT YOUR PERSONAL INFORMATION” section.
To Comply with Laws and Regulations. We will use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For Compliance, Fraud Prevention, and Safety. We may use personal information and disclose it to law enforcement, government authorities, emergency services, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of the Services, and our business, databases, and other technology assets; (b) protect our, your, our investors’, or others’ rights, property, privacy, safety (including for making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Services; and (e) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With Your Consent. We will disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.
SHARING OF PERSONAL INFORMATION
In addition to the specific situations discussed elsewhere in this Privacy Policy or at the point of collection, Wolff may share your personal information with the following entities or persons:
Related Companies. We may share your personal information with our affiliates, subsidiaries, and other related companies.
Service Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of our business. For example, we work with service providers that help us perform website hosting, maintenance services, database management, analytics, fraud protection, marketing, and investor relationship management.
Advertising Partners. We may also share personal information with third parties who we partner with for advertising campaigns or that collect information about your activity on the Services for the purposes described in the “Interest-Based Advertising” section above.
Professional Advisors. We may share personal information with persons, companies, or professional firms providing Wolff with advice and consulting in accounting, administrative, legal, tax, financial, and other matters.
Law Enforcement. Under certain circumstances, we may be required to disclose personal information to law enforcement, government authorities, and other parties if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
Authorities and Others for Compliance, Fraud Prevention, and Safety. We may disclose personal information in the good faith belief that such action is necessary to comply with a legal obligation or for the purposes described above in the section titled “For Compliance, Fraud Prevention, and Safety.”
Business Transaction Participants. We may disclose personal information to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).
CHOICES ABOUT YOUR PERSONAL INFORMATION
You can make the following choices regarding your personal information:
Marketing Emails. You may opt-out of marketing-related emails by clicking the “unsubscribe” link at the bottom of the email or by contacting us as described below.
Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Services and our Website may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
Advertising Choices. You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, and/or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp) and the Digital Advertising Alliance (https://optout.aboutads.info). Some of the companies we work with may offer their own opt-out mechanisms. For example, you can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here.
Many of the opt-out preferences described in this section must be set on each device and/or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
Do Not Track. Some browsers may be configured to send “Do Not Track” signals to the online services that you visit. The Services currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
SECURITY OF PERSONAL INFORMATION
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information.
OTHER SITES AND SERVICES
The Services may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
Wolff is based in the United States, and we have service providers in the United States and potentially other countries. Your personal information may be collected, used, and stored in these countries or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein.
CHILDREN’S PRIVACY
The Website is not intended for use by anyone under the age of 16, and we do not knowingly collect personal information from children under 16.
CONTACTING US
If you have any questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at privacy@awolff.com.
.
NOTICE TO CALIFORNIA RESIDENTS
This addendum applies only to California residents and supplements the information in our general Privacy Policy above. It describes how we collect, use, sell, share, and retain personal information of California residents, and their rights with respect to their personal information. For purposes of this Notice to California Residents, “personal information” has the meaning given under California privacy laws but does not include information exempted from the scope of such laws. In some cases, we may provide a different privacy notice to certain categories of California residents, in which case that notice will apply instead of this section.
Personal Information Collected and Purposes of Collection and Use. The list below summarizes the personal information we collect, or have collected in the 12 months preceding the “Last Updated” date of the Privacy Policy, by reference to the categories specified under California privacy laws. Examples in the list refer to the types of personal information described in our general Privacy Policy under the section titled “COLLECTION OF PERSONAL INFORMATION.”
- Identifiers, such as first and last name, email address, and the information associated with your requests or inquiries.
- Internet or Network Activity, such as online activity information and device information.
- Geolocation Data, such as device information.
We may collect these categories of personal information directly from you and from your device, from our service providers, advertising partners, and from other third parties as further described in our general Privacy Policy under the section titled “COLLECTION OF PERSONAL INFORMATION.”
The purposes, including the specific business or commercial purposes, for which we collect and use these categories of personal information are described in our general Privacy Policy under the section titled “USE OF PERSONAL INFORMATION.”
To the extent we collect sensitive personal information, we only use or disclose it for purposes permitted under California privacy laws (e.g., to perform the Services, detect security incidences and prevent fraud, and to verify and maintain the quality of the Services). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California residents.
Personal Information “Sold,” “Shared,” or Disclosed.
California privacy laws define “sale” as disclosing a California resident’s personal information to a third party for monetary or other valuable consideration. Where such disclosure is for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, it qualifies as “sharing” under California privacy laws.
The table below describes how we “sell,” “share,” and disclose personal information, including our practices in the 12 months preceding the “Last Updated” date of the Privacy Policy. The categories of third parties listed in the table are described in our general Privacy Policy under the section titled “SHARING OF PERSONAL INFORMATION.”
| Category of Personal Information | Whether the category of personal information is “sold” or “shared” and to whom | Whether the category of personal information is disclosed for a business purpose and to whom |
| Identifiers | To advertising partners
|
To related companies; service providers; advertising partners; professional advisors; and authorities and others for compliance, fraud prevention, and safety |
| Internet or Network Activity | To advertising partners | To related companies; service providers; and advertising partners |
| Geolocation Data | N/A | To related companies; service providers; and advertising partners |
We have “sold” or “shared” the categories of personal information indicated above for purposes of advertising our Services (including tracking the success of our advertising campaigns), identifying new or potential investors, and measuring activity on the Services, and the other purposes described in our general Privacy Policy under the section titled “USE OF PERSONAL INFORMATION.”
We do not knowingly “sell” or “share” the personal information of California residents under 16 years of age.
We disclosed for a business purpose the categories of personal information listed above for the purposes set forth in our general Privacy Policy.
Retention of Personal Information. We will retain each of the categories of personal information listed above for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your California Privacy Rights. As a California resident, in addition to the choices described in the general Privacy Policy, you have the rights listed below. However, these rights are not absolute, and, in certain cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.
- Right to Know. You have the right to request the following information about how we have collected and used your personal information:
- The categories of personal information we collected about you;
- The categories of sources from which that personal information was collected;
- Our business or commercial purpose for collecting, selling, or sharing (as applicable) that personal information; and
- The categories of third parties with whom we disclose that personal information (as applicable).
- Right to Access. You have the right to request a copy of the personal information that we have collected about you.
- Right to Delete. You have the right to request that we delete the personal information we have collected from you.
- Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you.
- Right to Opt-Out of Sales/Sharing. If we “sell” or “share” your personal information, you have the right to opt-out.
- Right to Nondiscrimination. You are entitled to exercise the rights described above without receiving discriminatory treatment.
How to Exercise Your California Privacy Rights. You may exercise the California privacy rights described above as follows:
- Requests to know, access, delete, or correct. Please submit these requests by using our interactive webform available by clicking here: Wolff Privacy Request, emailing privacy@awolff.com (with “CCPA Privacy Request” in the subject line), or calling us toll-free at 1-800-505-1381.
- Request to opt-out of the “sale” or “sharing” your personal information. To opt-out of “sharing,” please click on the “Your California Privacy Choices” link at the bottom of the Website and modify your cookie preferences, or broadcast the Global Privacy Control (GPC) signal. Note that due to technological limitations, if you visit our Services from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to this Website to select your preferences and/or rebroadcast the GPC signal. To opt-out of “sales,” we need to collect some identifying information. Please complete the interactive webform provided above to opt-out of “sales.”
If you direct us not to “sell” your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your rights to know, access, delete, and correct. This is a security measure to, for example, ensure we do not disclose personal information to any person who is not entitled to receive it. The verification process may vary depending on how you submit your request. We may also contact you to ask you for further information in relation to your request to speed up our response.
Consistent with California privacy laws, you may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify your request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is unfounded, repetitive, or excessive.
NOTICE TO NEVADA RESIDENTS
Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit a request to us using the contact information listed at the end of this Privacy Policy.